Turkey Point Nuclear Plant, Units 3 and 4 - Transmittal ... · Turkey Point (PTN), Units 3 and 4,...

UNITED STATES NUCLEAR REGULATORY COMMISSION

WASHINGTON DC 20555-0001

Barch 27 2012

Mr Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company PO Box 14000 Juno Beach Florida 33408-0420

SUBJECT TURKEY POINT UNITS 3 AND 4 - ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT RELATED TO THE PROPOSED EXTENDED POWER UPRATE (TAC NOS ME4907 AND ME4908)

Dear Mr Nazar

Enclosed is a copy of the Environmental Assessment (EA) and Finding of No Significant Impact (FONSI) related to your request for an amendment dated October 212010 as supplemented on December 142010 and April 22 2011 (on environmental issues) for Turkey Point Units 3 and 4 The proposed amendment would authorize increasing the maximum thermal power from 2300 megawatts thermal (MWt) to 2644 MWt This represents a net increase in core thermal power of approximately 15 percent including a 13 percent power uprate and a 17 percent measurement uncertainty recapture over the current licensed thermal power level and is defined as an Extended Power Uprate (EPU)

The assessment is being forwarded to the Office of the Federal Register for publication

Also enclosed is a summary of the comments received on the Draft EA and Draft FONSI that was published in the Federal Register on November 17 2011 (76 FR 71379)

ason C Paige Project Manager lant Licensing Branch 11-2

Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos 50-250 and 50-251

Enclosures 1 Environmental Assessment 2 Summary of Comments

cc wencls Distribution via Listserv

Additional distribution see next page

Letter to Mano Nazar from Jason Paige dated March 27 2012

Subject TURKEY POINT UNITS 3 AND 4middot ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT RELATED TO THE PROPOSED EXTENDED POWER UPRATE (TAC NOS ME4907 AND ME4908)

cc wencls

State of Florida Department of Environmental Protection

Cindy Mulkey Department of Environmental Protection Mail Station 48 3900 Commonwealth Blvd Tallahassee Florida 32399

Marc Harris Department of Environmental Protection Mail Station 48 3900 Commonwealth Blvd Tallahassee Florida 32399

South Florida Water Management District

Steve Krupa PG Hydrogeology Section SFWMD PO Box 24680 MS 4330 West Palm Beach FL 33416

Scott Burns Land Resources Staff SFWMD PO Box 24680 MS 4330 West Palm Beach FL 33416

MiamimiddotDade County Department of Environmental Resources Management

Craig K Grossenbacher Chief Natural Resources Planning Section Miami-Dade Department of Environmental Resources Management 701 NW 1 st Court 5th Floor Miami FL 33136-3912

National Park Service Biscayne National Park

Sarah Bellmund Biscayne National Park 9700 SW 328th Street Homestead FL 33033-5634

ENCLOSURE 1

NUCLEAR REGULATORY COMMISSION

[Docket Nos 50-250 and 50-251 NRC-2011-0259]

License Amendment

To Increase the Maximum Reactor Power Level Florida Power amp Light Company

Turkey Point Units 3 and 4

AGENCY Nuclear Regulatory Commission

ACTION Final environmental assessment and finding of no significant impact

SUMMARY The US Nuclear Regulatory Commission (NRC or the Commission) is

considering issuing an amendment for Renewed Facility Operating License Nos DPR-31 and

DPR-41 issued to Florida Power amp Light Company (FPL or the licensee) for operation of the

Turkey Point (PTN) Units 3 and 4 to increase the maximum power level from 2300 megawatts

thermal (MWt) to 2644 MWt for each unit The proposed power increase is approximately 15shy

percent over the current licensed thermal power including a 13-percent power uprate and a 17shy

percent measurement uncertainty recapture and approximately a 20-percent increase from the

original licensed power level of 2200 MWt The NRC did not identify any significant

environmental impacts associated with the proposed action based on its evaluation of the

information provided in the licensees application and other available information and has

prepared this final Environmental Assessment (EA) and Finding of No Significant Impact

(FONSI) for the proposed action

-2shy

ADDRESSES Please refer to Docket ID ltNRC-20YY-XXXXgt when contacting the NRC about

the availability of information regarding this document You may access information related to

this document which the NRC possesses and is publicly-available using the following methods

bull Federal Rulemaking Web site Go to httpwwwregulationsgov and search for

Docket ID ltNRC-20YY-XXXXgt Address questions about NRC dockets to Carol Gallagher

telephone 301-492-3668 e-mail CarolGallaghernrcgov

bull NRCs Agencywide Documents Access and Management System (ADAMS)

You may access publicly-available documents online in the NRC Library at

httpwwwnrcgovlreading-rmladamshtml To begin the search select ADAMS Public

Documents and then select Begin Web-based ADAMS Search For problems with ADAMS

please contact the NRCs Public Document Room (PDR) reference staff at 1-800-397-4209

301-415-4737 or bye-mail to pdrresourcenrcgov The ADAMS accession number for each

document referenced in this notice (if that document is available in ADAMS) is provided the first

time that a document is referenced

bull NRCs POR You may examine and purchase copies of public documents at the

NRCs PDR Room 01-F21 One White Flint North 11555 Rockville Pike Rockville Maryland

20852

FOR FURTHER INFORMATION CONTACT Jason Paige Project Manager Plant licensing

Branch 2-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation US

Nuclear Regulatory Commission Washington DC 20555-0001 telephone 301-415-5888

e-mail JasonPaigenrcgov

SUPPLEMENTARY INFORMATION

I Introduction

The US Nuclear Regulatory Commission (NRC) is considering issuance of an

amendment for Renewed Facility Operating License Nos DPR-31 and DPR-41 issued to FPL

for operation of the PTN Units 3 and 4 for a license amendment to increase the maximum

power level from 2300 MWt to 2644 MWt for each unit In accordance with Title 10 of the Code

of Federal Regulations (10 CFR) 5121 the NRC has prepared this final EA and FONSI for the

proposed action The proposed power increase is approximately 15-percent over the current

licensed thermal power including a 13-percent power uprate and a 17-percent measurement

uncertainty recapture and approximately a 20-percent increase from the original licensed power

level of 2200 MWt The NRC did not identify any Significant environmental impacts associated

with the proposed action based on its evaluation of the information provided in the licensees

application and other available information For further details with respect to the proposed

action see the licensees application dated October 21 2010 as supplemented by letters dated

December 142010 (ADAMS AcceSSion No ML 103560167) and April 22 2011

(ML11115A114)

The NRC published a notice in the Federal Register requesting public review and

comment on a draft EA and FONSI for the proposed action on November 17 2011 (76 FR

71379) and established December 19 2011 as the deadline for submitting public comments

By letters dated December 92011 (ADAMS Accession No ML 11347A194) and December 12

2011 (ADAMS Accession No ML 12027A023) comments were received from FPL and Mr

Steve Torcise Jr ofthe Atlantic Civil Inc respectively The FPL comments provided new

estimates on the number of additional workers needed to support the outage work implementing

the proposed Extended Power Uprate (EPU) and revised the projected outage times necessary

-4shy

to implement the EPU The FPL comments have been incorporated into this final EA with no

change to the FONSI conclusion The Atlantic Civil Inc comments have been incorporated into

this final EA with no change to the FONSI conclusion and are summarized in the Summary of

Comments (ADAMS Accession No ML12075A035) Also by letter dated January 122012

(ADAMS Accession Number ML 12019A348) the Southeast Regional Office of the US

Department of the Interiors National Park Service provided comments on the draft EA and draft

FONSI Since these comments were received after the comment period deadline of December

19 2011 the NRC will address these comments using separate correspondence

II Environmental Assessment

Plant Site and Environs

The PTN site is located on 11000 acres (ac) (4450 hectares (haraquo in Floridas South

Miami-Dade County approximately 25 miles (mi) (40 kilometers [km]) south of Miami Florida

The nearest city limits are Florida City approximately 8 miles (13 km) to the west Homestead at

approximately 45 miles (7 km) to the northwest and Key Largo at approximately 10 miles (16

km) south ofthe PTN site The PTN site is bordered to the east by Biscayne National Park

(BNP) to the north by the BNP and Homestead Bayfront Park and on the west and south by

FPLs 13000 ac (5260 hal Everglades Mitigation Bank The PTN site consists offive electric

generating units Units 3 and 4 at the PTN site are nuclear reactors Units 1 2 and 5 are fossilshy

fueled units and are not covered by the proposed licensing action Each nuclear reactor is a

Westinghouse pressurized light-water reactor with three steam generators producing steam that

turns turbines to generate electricity The site features a 5900 ac (2390 hal system of closed

reCirculating cooling canals that are used to cool the heated water discharged by Units 1

- 5shy

through 4 Unit 5 has mechanical draft cooling towers for the steam generation cycle using

water from the Upper Floridan Aquifer (UFA) as makeup and routing cooling tower blowdown to

the cooling canal system The five units and supporting equipment (excluding the cooling canal

system) occupy approximately 130 ac (53 ha)

In June 2009 FPL submitted an application for a combined construction permit and

operating license (COL) for two Westinghouse Advanced Passive 1000 (AP1000) pressurizedshy

water reactors (PWRs) deSignated as PTN Units 6 and 7

Background Information on the Proposed Action

By application dated October 21 2010 the licensee requested an amendment to its

license for an EPU for PTN Units 3 and 4 to increase the licensed thermal power level from

2300 MWt to 2644 MWt for each unit This represents an increase of approximately 15-percent

above the current licensed thermal power including a 13-percent power uprate and a 17shy

percent measurement uncertainty recapture This change requires NRC approval prior to the

licensee implementing the EPU The proposed action is considered an EPU by the NRC

because it exceeds the typical7-percent power increase that can be accommodated with only

minor plant changes An EPU typically involves extensive modifications to the nuclear steam

supply system contained within the plant buildings

The licensee plans to make extensive physical modifications to the plants secondary

side (ie non-nuclear) steam supply system to implement the proposed EPU These

modifications would occur during separate refueling outages for each unit The EPU-related

work for Unit 3 is scheduled for the spring 2012 outage and Unit 4 during the fall 2012 outage

-6

The EPU if approved by the NRC would be implemented following each units refueling outage

in 2012

Approximately 800 people are employed at PTN Units 3 and 4 on a full-time basis with

increases of approximately 600 - 900 during refueling outages The licensee estimates that it

will need approximately 2500 workers for implementation of the EPU resulting in a potential

maximum outageEPU workforce of approximately 3400 during each of the EPU outages

As part of the overall process to obtain approval for the EPU in September 2007 FPL

submitted a Petition to Determine Need for Expansion of Electrical Power Plants to the Florida

Public Service Commission (FPSC) The petition contained FPLs analysis for meeting the

need for electric system reliability integrity and providing adequate electricity at a reasonable

cost how the proposed EPU is the most cost-effective alternative available and why there are

no renewable energy sources and technologies or conservation measures reasonably available

to FPL that would avoid or mitigate the need for the proposed EPU On January 72008 the

FPSC issued a Final Order Granting Petition for Determination of Need approving the proposed

expansion of PTN Units 3 and 4 based on compliance with conditions required by the state

The Need for the Proposed Action

As stated in the FPLs application the proposed action is to provide an additional supply

of electric generation in the State of Florida without the need to site and construct new facilities

The proposed EPU will increase the electrical output for each unit by about 104 megawatts

electric (MWe) from about 700 MWe to about 804 MWe

Environmental Impacts of the Proposed Action

- 7shy

As part of the original licensing process for PTN Units 3 and 4 the NRC published a

Final Environmental Statement (FES) in July 1972 The FES contains an evaluation of the

potential environmental impacts associated with the operation of PTN Units 3 and 4 over their

licensed lifetimes In 2002 the NRC evaluated the environmental impacts of renewing the

operating license of PTN Units 3 and 4 for an additional 20 years beyond its current operating

license The NRC concluded that the overall environmental impacts of license renewal were

small This evaluation is presented in NUREG-1437 Generic Environmental Impact Statement

for License Renewal of Nuclear Plant Supplement 5 Regarding Turkey Point Units 3 and 4

(EIS Supplement NO5 (SEIS-5raquo issued in January 2002 (ADAMS Accession Nos

ML020280119 ML020280202 and ML020280226) Additionally in October 2008 the State of

Florida Department of Environmental Protection (FDEP) completed a thorough and

comprehensive review under the Florida Electrical Power Plant Siting Act and issued a site

certification to FPL approving the proposed EPU for PTN Units 3 and 4 In June 2009 FPL

submitted an application for a COL for two AP1000 PWRs designated as PTN Units 6 and 7

The COL application included an Environmental Report ER with FPLs analysis of the

reasonably foreseeable impacts to the environment from the construction and operation of the

two new units along with an environmental description of the existing PTN site The NRC staff

used information from the licensees license amendment request for the EPU the FESs SEIS-5

to NUREG-1437 documents related to the FDEP site certification process and information

provided in the Turkey Point COL Environmental Report to perform its EA for the proposed EPU

for PTN Units 3 and 4

In order to implement the EPU significant modifications will be required to the steam

and power conversion equipment located within the buildings of PTN Units 3 and 4 Two

changes outside of the reactor buildings including a change to the electric switchyard to

8shy

accommodate new electrical equipment and construction of a temporary warehouse for EPUshy

related equipment would occur in developed portions of the power plant site Modifications to

the secondary side (Le non-nuclear) of each unit include the following replacing the highshy

pressure turbine modifying condensate pump operations installing fast acting backup

automatic feedwater isolation valves replacing two feedwater heaters providing supplemental

cooling for selected plant systems implementing electrical upgrades system modifications to

accommodate greater steam and condensate flow rates and changing system setpoints and

associated software

The sections below describe the potential nonradiological and radiological impacts to the

environment that could result from the proposed EPU

Nonradiological Impacts

Land Use and Aesthetic Impacts

Potential land use and aesthetic impacts from the proposed EPU include impacts from

plant modifications at the PTN site While some plant components would be modified most

plant changes related to the proposed EPU would occur within existing structures buildings

and fenced equipment yards housing major components within the developed part of the site

As previously discussed EPU-related modifications at the PTN plant site would occur within the

developed portions of the power plant site

Existing parking lots road access equipment lay-down areas offices workshops

warehouses and restrooms would be used during plant modifications Therefore land use

conditions would not change at the PTN site Also there would be no land use changes along

transmission line corridors and no new transmission lines would be required The PTN Units 3

-9shy

and 4 electric switchyard would be expanded to accommodate new equipment which will be

expanded on previously disturbed or already developed portions of the PTN site

Since land use conditions would not change at the PTN site and because any land

disturbance would occur within previously disturbed areas there would be little or no impact to

aesthetic resources in the vicinity of PTN Units 3 and 4 Therefore there would be no

significant impact from EPU-related plant modifications on land use and aesthetic resources in

the vicinity of the PTN site

Air Quality Impacts

Major air pollution emission sources at the PTN site are regulated by the FDEPs

Division of Air Resource Management under the Prevention of Significant Deterioration

program Nonradioactive emission sources at PTN Units 3 and 4 consist of four 25 MWe

emergency generators five smaller emergency generators and various general purpose

generators regulated under a Florida Title V Air Operating Permit There will be no changes to

the emissions from these sources as a result of the EPU

Some minor and short duration air quality impacts would occur during implementation of

the EPU at the PTN site The main source of air emissions would come from the vehicles

driven by outage workers needed to implement the EPU However air emissions from the EPU

workforce truck deliveries and constructionmodification activities would not be significantly

greater than previous refueling outages at the PTN site

Upon completion of the proposed EPU nonradioactive air pollutant emissions would not

increase Therefore there would be no significant impact on air quality in the region during and

following implementation of the proposed EPU

-10shy

Water Use Impacts

Surface Water

The PTN Units 3 and 4 are located in the low-lying areas of coastal Miami-Dade County

on the western shore of Biscayne Bay There are no significant freshwater surface bodies

outside of the PTN site (ie lakes major rivers or dams) but there is a network of canals such

as the Everglades National Park-South Dade Conveyance System in addition to local drainage

canals that either control drainage from southeast Florida to Biscayne Bay or provide freshwater

to the Everglades National Park The most significant surface water body on the PTN site is the

closed-cycle cooling canal system (CCS) permitted by the State of Florida as an industrial

wastewater facility used for the cooling of heated water discharged from the main condensers

and auxiliary systems of PTN Units 1 through 4

The CCS covers approximately 5900 ac (2390 ha) of the PTN site with a large system

of north-south aligned 168 miles of interconnected earthen canals to dissipate heat through

surface evaporation The canals are a closed recirculating loop that serves as the ultimate heat

sink for PTN Units 3 and 4 The CCS is operated under an industrial wastewater facility No

Discharge National Pollutant Discharge Elimination System (NPDES) permit from the FDEP

(NPDES permit number FLOOO1562) for water discharges to an onsite closed-loop recirculation

cooling canal system The seasonal temperature of the canal water ranges from approximately

85 of to 105 OF (29degC to 40degC) for heated water entering the CCS with cooled water returning

to the power plants at approximately 70 of to 90 OF (21degC to 32degC) Additionally the CCS

water is hyper-saline (twice the salinity of Biscayne Bay) with seasonal variations ranging from

approximately 40 to 60 parts per thousand (ppt)

The CCS does not discharge directly to fresh or marine surface waters Makeup water

to replace water lost due to evaporation comes from used plant process water that has been

- 11 shy

treated incident rainfall storm water runoff and from infiltration and exchange of saline water

with local groundwater and Biscayne Bay Because the PTN canals are unlined there is an

exchange of water between the PTN canal system and local groundwater and Biscayne Bay

An interceptor ditch is located along the west side of the CCS During the dry season when the

natural groundwater gradient is from Biscayne Bay and Card Sound toward the Everglades

water is pumped from the interceptor ditch to the CCS to create an artificial groundwater

gradient from the Everglades into the ditch This process is used to minimize the flow of hypershy

saline water from the CCS toward the Everglades Maintenance of the CCS includes

mechanical removal of submerged rooted marine plants on an approximate 3-year cycle and

removal of terrestrial woody vegetation from the canal berms on a 1Q-year cycle

Each nuclear unit discharges approximately 535 billion British Thermal Units (BTU) per

hour of waste heat to the CCS Under the proposed EPU the quantity of waste heat discharged

by each nuclear unit to the CCS would increase to approximately 610 billion BTU per hour

This results in a net total increase of 15 billion BTU in waste heat discharged by both nuclear

units The licensee calculated that the maximum change in water temperature due to the

proposed EPU would be approximately 20 OF to 25 OF (11 degc to 14 (lC) for a total maximum

water temperature up to 1086 OF (426 0c) for water entering the CCS and a 09 OF (05 degC)

increase with a total maximum water temperature up to 928 OF (338 0c) for the water returning

to the power plants The licensee calculated that the higher water temperature will increase

water losses from the CCS due to evaporation resulting in a slight increase in salinity of

approximately 2 to 3 ppt

In accordance with the FDEP site certification process for the proposed EPU FPl must

meet state imposed requirements contained in the Conditions of Certification (CoC) The CoC

was developed based on interactions by FPl with the FDEP and other stakeholders including

- 12 shy

opportunities for public comment during the FDEP site certification process The inclusion of

stakeholders recommendations into the CoC formed the basis for FDEP recommending

approval of the site certification application for the proposed EPU The CoC requires FPL to

have a program to monitor and assess the potential direct and indirect impacts to ground and

surface water from the proposed EPU The monitoring includes measuring water temperature

and salinity in the CCS and monitoring the American crocodile populations at the PTN site The

monitoring plan expands FPLs monitoring of the CCSs ground and surface water to include the

land and water bodies surrounding the PTN site such as Biscayne Bay

The implementation of the CoC monitoring plan is an ongoing program coordinated by

FDEP The results of the monitoring will be publicly available via a South Florida Water

Management District (SFWMD) website If the proposed EPU is approved by the NRC the CoC

monitoring plan would continue to assess the environmental impacts The CoC allows FDEP to

impose additional measures if the monitoring data is insufficient to adequately evaluate

environmental changes or if the data indicates a significant degradation to aquatic resources by

exceeding State or County water quality standards or the monitoring plan is inconsistent with

the goals and objectives of the Comprehensive Everglades Restoration Plan Biscayne Bay

Coastal Wetlands Project Additional measures could include enhanced monitoring modeling

or mitigation Abatement actions provided in the CoC include mitigation measures to comply

with State and local water quality standards which may include methods to reduce and mitigate

salinity levels in groundwater operational changes to the PTN cooling canal system to reduce

environmental impacts and other measures required by FDEP in consultation with SFWMD and

Miami-Dade County to reduce the environmental impacts to acceptable levels

The field data on surface water monitoring currently available are being reviewed by

FPL FDEP SFWMD and stakehOlders for the development of a water budget model The data

- 13shy

and other documentation show that there is indirect surface water communication between the

CCS and Biscayne Bay Approving the proposed EPU license amendment is not expected to

cause significant impacts greater than current operations because the monitoring plan will

provide data for FPL and state agencies to assess the effectiveness of current environmental

controls and additional limits and controls could be imposed if the impacts are larger than

expected Therefore there would be no significant impact to surface water resources following

implementation of the proposed EPU

Groundwater

Southeastern MiamiDade County is underlain by two aquifer systems the unconfined

Biscayne Aquifer and the Floridan Aquifer System (FAS) The Biscayne Aquifer has been

declared a sole-source aquifer by the US Environmental Protection Agency (EPA) The

Biscayne Aquifer underlying the PTN site however contains saline to saltwater in this area and

is not usable as a potable water supply The FAS underlies approximately 100000 square

miles (258000 km2) in southern Alabama southeastern Georgia southern South Carolina and

all of Florida The FAS is a multiple-use aquifer system in that where it contains freshwater it is

the prinCipal source of water supply Where the aquifer contains saltwater such as along the

southeastern coast of Florida treated sewage and industrial wastes are injected into it

Recharge of groundwater at the PTN site varies seasonally between surface recharge

during the rainy season and saline recharge from the ocean during the dry season As a result

there is a large seasonal variation in the salinity of the groundwater near the surface at the PTN

site However below about 40 ft (12 meters (mraquo into the Biscayne aquifer relatively high

salinity (greater than 28 ppt) exists year round Florida classifies the groundwater in this area

- 14shy

as G-III based on its salinity This classification is used to identify groundwater that has no

reasonable potential as a future source of drinking water due to high total dissolved solids

The current and proposed operations at the PTN site do not require the withdrawal of

groundwater The potable water and general service water supply at the PTN site are provided

by Miami-Dade County public water supply This potable water comes from the Biscayne

Aquifer which occurs at or close to the ground surface and extends to a depth of about 70 ft (21

m) below the surface The PTN Units 3 and 4 use approximately 690 gallons per minute (2612

liters per minute (Uminraquo of potable water The licensee is not requesting an increase in water

supply under the proposed EPU Therefore no significant impacts to offsite users of the Miamishy

Dade public water supply are expected

As discussed in the surface water impacts section the FPLs implementation of the CoC

monitoring plan is ongoing and consists of an integrated system of surface groundwater

vadose zone and ecologic sampling Fourteen groundwater monitoring well clusters at

selected sites have been constructed in accordance with the monitoring plan and an associated

quality assurance plan The field data collected prior to implementation of the proposed EPU

will be used to characterize existing environmental conditions from current PTN operations The

CoC allows the FDEP to require additional measures if the pre- and post-EPU monitoring data

are insufficient to evaluate changes as a result of the EPU If the data indicate an adverse

impact additional measures including enhanced monitOring modeling or mitigation would

likely be required to evaluate or to abate such impacts

Abatement actions provided in the CoC include (1) mitigation measures to offset such

impacts of the proposed EPU necessary to comply with State and local water quality standards

(2) operational changes in the cooling canal system to reduce impacts and (3) other measures

15 shy

to abate impacts specified a revised CoC approved by the FDEP after consultation with

SFWMD and Miami-Dade County

Approving the proposed EPU license amendment is not expected to cause significant

impacts greater than current operations because the monitoring plan will provide data for FPL

and state agencies to assess the effectiveness of current environmental controls and additional

limits and controls could be imposed if the impacts are larger than expected Therefore there

would be no significant impact to the groundwater following implementation of the proposed

EPU

Aquatic Resources Impacts

The discharges of chemicals and heated wastewater from PTN Units 3 and 4 have the

potential to impact aquatic biota from the proposed EPU Biscayne Bay and Card Sound are

shallow subtropical marine waters located between the mainland and a grouping of barrier

islands that form the northernmost Florida Keys These waters contain a variety of marine life

including seagrass sponges mollusks crustaceans fish sea turtles and marine mammals

The portion of Biscayne Bay adjacent to Turkey Point is part of Biscayne National Park which

includes the mainland shore the bay the keys and offshore coral reefs The Intracoastal

Waterway traverses Biscayne Bay and Card Sound and a barge passage runs from the

Intracoastal Waterway to the fossil-fueled facility at the PTN site Biscayne Bay and Card

Sound would be unaffected by the proposed EPU because FPL does not withdraw or discharge

to any natural water body

Turkey Points cooling system receives heated water discharged from the two reactors

as well as from the two fossil fueled electric generating stations The cooling system spans

about 5900 ac (2400 hal spread out over a 5 mi by 2 mi (8 km by 32 km) area of the site The

- 16shy

heated water is discharged into a series of 32 feeder channels that dissipate the heat The

feeder channels merge into a single collector canal that returns the cooled water to the plants

through a main return canal and six return channels

Under EPU conditions the cooling canal system would increase in both temperature and

salinity The licensee predicts that discharged water would increase a maximum of an

additional 25 of (14 degC) which would increase the change in temperature as water passes

through the condensers from 168 of to 188 of (93 to 104 degC) Because condenser cooling

water discharges at the northeastern corner of the cooling canal system flows west and then

south the system exhibits a north-south temperature gradient Therefore while the northeast

portion of the system may increase by 20 OF to 25 OF (11 degC to 14 degC ) under EPU conditions

the temperature increase attributable to the EPU would decrease as water moves south through

the system The increased discharge temperatures will cause additional evaporative losses to

the cooling canal system The Florida Department of Environmental Protection predicted that

an additional 2 to 3 million gallons per day (7600 to 11000 cubic meters per day) will be lost to

evaporation under EPU conditions The increased evaporation WOUld in turn increase the

cooling canals salinity of 40 to 60 ppt by 2 to 3 ppt Due to the north-south temperature

gradient evaporative losses would be greater in the northern portion of the canal system and

thus salinity will also demonstrate a north-south gradient

The cooling canal system supports a variety of aquatic species typical of shallow

subtropical hyper-saline environments including phytoplankton zooplankton marine algae

rooted plants crabs and estuarine fish The most abundant fish in the cooling canal system is

killifish (Family Cyprinidontidae) The aquatic species found within the cooling canal system are

subtropical or tropical and readily adapt to hyper saline environments The aquatic populations

- 17 shy

within the cooling canal system do not contribute any commercial or recreational value because

the cooling canal system is owner-controlled and closed to the public

Because aquatic organisms in the cooling canal system are unable to travel to or from

Biscayne Bay Card Sound or any other natural water body changes to the conditions within

the cooling canal system would not affect any aquatic species populations in the natural aquatic

habitats Therefore the staff concludes that there would be no significant impacts to aquatic

resources as a result of the proposed EPU

Terrestrial Resources Impacts

The PTN site is situated on low swampy land that was previously mangrove-covered

tidal flats Mangrove swamps extend inland approximately 3 to 4 mi (5 to 65 km) and

undeveloped portions of the site remain under 1 to 3 inches (2 to 8 centimeters) of water even

during low tide Of the 24OOO-ac (9700-ha) site approximately 11OOO-ac is developed for

PTN Units 3 and 4 the cooling canal system and three FPL-owned fossil fuel units

The impacts that could potentially affect terrestrial resources include loss of habitat

construction and refurbishment-related noise and lighting and sediment transport or erosion

Because all activities associated with the EPU would occur on the developed portion of the site

the proposed EPU would not directly affect any natural terrestrial habitats and would not result

in loss of habitat Noise and lighting would not impact terrestrial species beyond what would be

experienced during normal operations because refurbishment and construction activities would

take place during outage periods which are already periods of heightened activity Sediment

transport and erosion is not a concern because activity would only take place on previously

developed land and best management practices would ensure that no loose sediment is

- 18shy

transported to wetland areas tidal flats or waterways The staff concludes that the proposed

EPU would have no significant effect on terrestrial resources

Threatened and Endangered Species Impacts

Under Section 7 of the Endangered Species Act of 1973 as amended (ESA) Federal

agencies in consultation with the US Fish and Wildlife Service (FWS) or the National Marine

Fisheries Service (as appropriate) must ensure that actions the agency authorizes funds or

carries out are not likely to jeopardize the continued existence of any listed species or result in

the destruction or adverse modification of critical habitat

In order to fulfill its duties under section 7 of the ESA the NRC prepared and submitted

a biological assessment to the FWS on September 9 2011 in order to determine the potential

effects of the proposed EPU on Federally listed species The following Table identifies the

species that the NRC considered in its biological assessment

Table of Federally Listed Species Occurring in Miami-Dade County

Scientific Name Common Name ESA Statusa)

Aquatic Invertebrates

Acropora cervicornis stag horn coral PT Acropora palmate elkhorn coral PT

Ammodramus maritimus mirabilis

Charadrius melodus

Dendroica kirtlandii

Mycteria americana

Polyborus plancus audubonii

Rostrhamus sociabilis plumbeus

Vennivora bachmanii

Cape Sable seaside sparrow E

piping plover T

Kirtlands warble~b) E

wood stork E Audubons crested caracara(b) T

Everglade snail kite E

Bachmans warblerb ) E

Fish

Pristis pectinata smalltooth sawfish E

Flowering Plants --_

Amorpha crenulata

Chamaesyce detoidea ssp Deltoidea

Chamaesyce garberi

Cucurbita okeechobeensis ssp Okeechobeensis

Gaactia smalfii

Halophia johnson

Jacquemontia reclinata

Polygala smallii

- 19shy

crenulate lead-plant E

deltoid spurge E

Garbers spurge T

okeechobee gourd(b) E

Smalls milkpea E

Johnsons sea grass T

beach jacquemontia E

tiny polygala E

Heradides aristodemus ponceanus schaus swallowtail butterfly E

Puma concolor mountain lion(D) TSA

Felis concolor coryi Florida panther E

Trichechus manatus West Indian manatee E

Reptiles

Alligator mississippiensis American alligator TSA

Caretta caretta loggerhead sea turtle T

Chelonia mydas green sea turtle E

Crocodylus acutus American crocodile T

Dermochelys coriacea leatherback sea turtle E

Drymarchon corais couperi eastern indigo snake T

Eretmochelys imbricata hawksbill sea turtle E

Lepidochelys kempii Kemps ridley sea turtle(C) E

Snails

Orthaicus reses Stock Island tree snail(b) T

(alE =endangered PT =proposed threaten T =threatened TSA = threatened due to similarity of appearance

(b)Species not previously considered in 2001 biological assessment for Turkey Point

(C)The Kemps ridley is not listed by the FWS as occurring in Miami-Dade County However the species occurs in the neighbOring Monroe County and FPL has reported the species occurrence in Biscayne Bay and Card Sound

Source US Fish and Wildlife Service

- 20shy

In the biological assessment the NRC concluded that the proposed EPU may adversely

affect the American crocodile (Crocodyus acutus) The NRC concluded that the proposed EPU

would not adversely affect the remaining 30 species listed in the Table above The NRC also

concluded that the proposed EPU may adversely modify the cooling canal system which is

designated as a critical habitat for the American crocodile

The FWS responded to NRCs biological assessment on October 25 2011 In their

letter the FWS concluded that the proposed EPU may affect but is not likely to adversely

affect the American crocodile The FWS also noted that the proposed EPU is unlikely to result

in modification to designated American crocodile critical habitat This letter fulfilled the NRCs

requirements under Section 7 of the ESA

Based on the FWSs conclusions the NRC concludes that the proposed EPU would not

significantly impact threatened or endangered species

Historic and Archaeological Resources Impacts

As reported in the SEIS-5 the NRC reviewed historic and archaeological site files at the

Florida Department of State Division of Historical Resources the National Park Service

Southeast Archaeological Center and at Biscayne National Park and confirmed that no historic

or archaeological and historic architectural sites have been recorded on the PTN site As

previously discussed EPU-related plant modifications would take place within existing buildings

and facilities at PTN except for the expansion of the switchyard on previously disturbed land

Since ground disturbance or construction-related activities would not occur outside of previously

disturbed areas there would be no significant impact from the proposed EPU on historic and

archaeological resources in the vicinity of PTN Units 3 and 4 and the switchyard

- 21

Socioeconomic Impacts

Potential socioeconomic impacts from the proposed EPU include increased demand for

short-term housing public services and increased traffic in the region due to the temporary

increase in the number of workers at the PTN site required to implement the EPU The

proposed EPU could also increase tax payments due to increased power generation


increases of approximately 600 - 900 during periodic refueling outages These workers reside

primarily in Miami-Dade County Florida The licensee estimates that it will need approximately

2500 workers for implementation of the EPU resulting in a potential maximum outageEPU

workforce of approximately 3400 during each of the EPU outages The licensee estimates that

the outages to implement the EPU will last approximately 160 days for Unit 3 and 130 days for

Unit 4 As previously discussed EPU-related modifications would take place during the spring

and fall 2012 refueling outages for Units 3 and 4 respectively Once EPU-related plant

modifications have been completed the size of the refueling outage workforce would return to

normal levels with no significant increases expected during future refueling outages The size

of the regular plant workforce is not expected to be affected by the proposed EPU

Most of the EPU-related plant modification workers would be expected to relocate

temporarily to Miami-Dade County resulting in short-term increases in the local population

along with increased demands for public services and housing Because plant modification

work would be short-term and up to half a year most workers would stay in available rental

homes apartments mobile homes and camper-trailers According to the 2010 census housing

data there were approximately 122000 vacant housing units in Miami-Dade County available to

meet the demand for rental housing Additionally there are over 200000 available public

lodging accommodations in Miami-Dade County Therefore a temporary increase in plant

- 22shy

employment for this duration would have little or no noticeable effect on the availability of

housing and public services in the region

The principal road access to the PTN site is via East Palm Drive (SW 344 Street) East

Palm Drive is a two-lane road for approximately half of its length from the PTN plant to Florida

City where it intersects with US Highway 1 approximately 14 km (9 miles) from the PTN site

Increased traffic volumes during normal refueling outages typically have not degraded the level

of service capacity on local roads The FPL evaluation asserts that the projected traffic will

remain well within the Miami-Dade County peak hour capacity Therefore the roadways used

by plant workers and the public are expected to operate at an acceptable level of service as

designated by Miami-Dade County However the additional number of workers and truck

material and equipment deliveries needed to support EPU-related plant modifications could

cause short-term level of service impacts on access roads in the immediate vicinity of PTN

During periods of high traffic volume (Le morning and afternoon shift changes) work schedules

could be staggered and employees andor local police officials could be used to direct traffic

entering and leaving the PTN site to minimize level of service impacts on SW 334th Street (East

Palm Drive)

Tangible personal property (principally business eqUipment) and real property (namely

land and permanent buildings) are subject to property tax in Florida as administered by the local

government For 2007 FPL paid approximately $69 million to Miami-Dade County and the

Miami-Dade school district in real property taxes for PTN Units 3 and 4 Future property tax

payments could take into account the increased value of PTN Units 3 and 4 as a resuH of the

EPU and increased power generation

Due to the short duration of EPU-related plant modification activities there would be little

or no noticeable effect on tax revenues generated by temporary workers residing in Miami-Dade

- 23shy

County Therefore there would be no significant adverse socioeconomic impacts from EPUshy

related plant modifications and operations under EPU conditions in the vicinity of the PTN site

Environmental Justice Impacts

The environmental justice impact analysis evaluates the potential for disproportionately

high and adverse human health and environmental effects on minority and low-income

populations that could result from activities associated with the proposed EPU at the PTN site

Such effects may include human health biological cultural economic or social impacts

Minority and low-income populations are subsets of the general public residing in the vicinity of

the PTN site and all are exposed to the same health and environmental effects generated from

activities at PTN Units 3 and 4

The NRC considered the demographic composition of the area within a 50-mi (80-km)

radius of the PTN site to detennine the location of minority and low-income populations and

whether they may be affected by the proposed action

Minority populations in the vicinity of the PTN site according to the US Census Bureau

data for 2000 comprise approximately 70 percent of the population (approximately 2170000

individuals) residing within a 50-mile (aO-kilometer) radius of the PTN site The largest minority

group was Hispanic or latino (approximately 1465000 persons or 47 percent) followed by

Black or African Americans (approximately 670000 persons or about 22 percent)

According to the US Census Bureau about 83 percent of the Miami-Dade County

population identified themselves as minorities with persons of Hispanic or latino origin

comprising the largest minority group (63 percent) According to 2009 American Community

Survey census data 1-year estimate as a percent of total population the minority population of

- 24shy

Miami-Dade County increased approximately one percent with persons of Hispanic or Latino

origin comprising the largest minority group (82 percent) in 2009

According to 2000 census data low-income populations comprised approximately

98000 families and 488000 individuals (approximately 13 and 16 percent respectively)

residing within a 50-mi (80-km) radius of the PTN site

The 2009 Federal poverty threshold was $22490 for a family of four with one related

child under 18 years According to census data in the 2009 American Community Survey

1-Year Estimate the median household income for Florida was $53500 with 11 percent of

families and 15 percent of individuals determined to be living below the Federal poverty

threshold Miami-Dade County had a lower median household income average ($42000) than

the State of Florida and also had higher percentages of county families (14 percent) and

individuals (18 percent) respectively living below the poverty level

Environmental Justice Impact Analysis

Potential impacts to minority and low-income populations would mostly consist of

environmental and socioeconomic effects (eg noise dust traffic employment and housing

impacts) Radiation doses from plant operations after the EPU are expected to continue to

remain below regulatory limits

Noise and dust impacts would be short-term and limited to onsite activities Minority and

low-income populations residing along site access and the primary commuter roads through

Florida City Florida (eg US Highway 1 and East Palm Drive) could experience increased

commuter vehicle traffic during shift changes Increased demand for rental housing during

EPU-related plant modifications could disproportionately affect low-income populations

However due to the short duration of the EPU-related work and the availability of rental

- 25shy

housing impacts to minority and low-income populations would be short-term and limited

According to 2010 census information there were approximately 122000 vacant housing units

in Miami-Dade County and approximately 20000 vacant housing units in Monroe County

Based on this information and the analysis of human health and environmental impacts

presented in this environmental assessment the proposed EPU would not have

disproportionately high and adverse human health and environmental effects on minority and

low-income populations residing in the vicinity of the PTN site

Nonradiological Cumulative Impacts

The NRC considered potential cumulative impacts on the environment resulting from the

incremental impact of the proposed EPU when added to other past present and reasonably

foreseeable future actions For the purposes of this analysis past actions are related to the

construction and licensing of PTN Units 3 and 4 present actions are related to current

operations and future actions are those that are reasonably foreseeable through the end of

station operations including operations under the EPU

The application to build two new nuclear units at the PTN site is considered a reasonably

foreseeable future action that is considered in this review A COL application was submitted by

FPL to the NRC in June 2009 for the construction and operation of two Westinghouse AP1 000

units at the PTN site along with the construction of transmission corridors It is expected

however that the proposed EPU if approved would be completed prior to the construction of

the new units Thus the cumUlative impacts briefly discussed in this section consider PTN

Units 3 and 4 operations (under the EPU) combined with the environmental impacts from the

proposed construction and operation of PTN Units 6 and 7

- 26shy

It is important to note that submitting the COL application does not commit FPL to build

two new nuclear units and does not constitute approval of the proposal by the NRC The COL

application will be evaluated on its merits and after considering and evaluating the

environmental and safety implications of the proposal the NRC will decide whether to approve

or deny the licenses Environmental impacts of constructing and operating PTN Units 6 and 7

will depend on their actual design characteristics construction practices and power plant

operations These impacts will be assessed by the NRC in a separate National Environmental

Policy Act (NEPA) document The cumulative impacts presented in this EA may differ from

those impacts assessed for the COL

For some resource areas (eg air quality water aquatic terrestrial resources and

threatened and endangered species) the contributory effect of ongoing actions within a region

are regulated and monitored through a permitting process (eg NPDES and 401404 permits

under the Clean Water Act) under State or Federal authority In these cases impacts are

managed as long as these actions are in compliance with their respective permits and

conditions of certification

Units 6 and 7 of the PTN site would be constructed on undeveloped land immediately

south of PTN Units 3 and 4 The EPU modifications to PTN Units 3 and 4 are expected to be

completed before the proposed PTN Units 6 and 7 are constructed

Units 6 and 7 of the PTN site would have a closed-cycle cooling system utilizing cooling

towers with makeup water from Biscayne Bay and treated wastewater from Miami-Dade County

Waste water discharges are expected to be disposed of by deep well injection Impacts to

water resources for PTN Units 3 and 4 and PTN Units 6 and 7 would occur separately and any

potential cumulative impacts would not be significantly greater than current operations

- 27shy

Units 6 and 70f the PTN site transmission lines and related infrastructure improvements

would be constructed and operated according to Federal and State regulations permit

conditions existing procedures and established best management practices Nevertheless

wildlife may be destroyed or displaced during land clearing for PTN Units 6 and 7 Less mobile

animals such as reptiles amphibians and small mammals would incur greater mortality than

more mobile animals such as birds Although undisturbed habitat would be available for

displaced animals during construction increased competition for available habitat may result in

local population stresses As construction activities end habitats could be restored either

naturally or through mitigation activities

Terrestrial species and habitat could be affected by PTN Units 6 and 7 cooling system

operations As described in the Environmental Report for the new units the primary source of

makeup water would be treated waste water from the Miami-Dade Water and Sewer

Department If not enough reclaimed water is available to meet the needs of PTN Units 6 and

7 then seawater would be withdrawn from under Biscayne Bay via radial collector wells

Because of this situation the operation of mechanical draft cooling towers can result in salt

deposition (Le salt drift) a greater risk of avian collision mortality and noise

Land needed for the proposed PTN Units 6 and 7 has been surveyed for historical and

archaeological sites The survey identified no new or previously recorded historic or

archaeological resources within or adjacent to the proposed site

Socioeconomic impacts from the construction and operation of PTN Units 6 and 7 would

occur several years after the EPU The large construction and operation workforces combined

with ongoing operation of PTN Units 3 and 4 under the EPU would have a noticeable effect on

socioeconomic conditions in local communities from the increased demand for temporary and

permanent housing public services (eg public schools) and increased traffic

- 28shy

Nonradiol()gicallmpacts Summary

As discussed above the proposed EPU would not result in any significant

nonradiological impacts Table 1 summarizes the nonradiological environmental impacts of the

proposed EPU at PTN Units 3 and 4

Table 1 Summary of Nonradiological Environmental Impacts

I Land Use The proposed EPU is not expected to cause a significant impact on land use conditions and aesthetic resources in the vicinity of the PTN

Air Quality The proposed EPU is not expected to cause a significant impact to air quality

Water Use The proposed EPU is not expected to cause impacts significantly greater than current operations No significant impact on groundwater or surface water resources

Aquatic Resources The proposed EPU is not expected to cause impacts significantly greater than current operations No significant impact to aquatic resources due to chemical or thermal discharges

Terrestrial Resources

The proposed EPU is not expected to cause impacts significantly greater than current operations No significant impact to terrestrial resources

Threatened and Endangered Species

The proposed EPU would not cause impacts significantly greater than current operations No significant impact to federally-listed species

Historic and Archaeological Resources

No significant impact to historic and archaeological resources on site or in the vicinity of the PTN

Socioeconomics No significant SOCioeconomic impacts from EPU-related temporary increase in workforce

Environmental Justice

No disproportionately high and adverse human health and environmental effects on minority and low-income populations in the vicinity of the PTN site

- 29

Cumulative Impacts The proposed EPU would not cause impacts significantly greater than current operations To address potential cumulative impacts for water and ecological resources a monitoring plan for the PTN site has been implemented The State of Florida has authority to impose limits on nonradiological discharges to abate any significant hydrology and ecology impacts

The NRC staff has not identified any significant cumulative impacts associated with construction and operation of Units 6 and 7 however the NRC will prepare a separate Environmental Impact Statement documenting the potential impacts associated with the construction and operation of Units 6 and 7

Radiological Impacts

Radioactive Gaseous and Liquid Effluents and Solid Waste

The PTN uses waste treatment systems to collect process recycle and dispose of

gaseous liquid and solid wastes that contain radioactive material in a safe and controlled

manner within NRC and EPA radiation safety standards The licensees evaluation of plant

operation at the proposed EPU conditions shows that no physical changes would be needed to

the radioactive gaseous liquid or solid waste systems

Radioactive Gaseous Effluents

The gaseous waste management systems include the radioactive gaseous system

which manages radioactive gases generated during the nuclear fission process Radioactive

gaseous wastes are principally activation gases and fission product radioactive noble gases

resulting from process operations including continuous degasification of systems gases

collected during system venting gases used for tank cover gas and gases generated in the

radiochemistry laboratory The licensees evaluation determined that implementation of the

proposed EPU would not significantly increase the inventory of carrier gases normally

processed in the gaseous waste management system since plant system functions are not

- 30shy

changing and the volume inputs remain the same The analysis also showed that the proposed

EPU would result in an increase in the equilibrium radioactivity in the reactor coolant which in

turn increases the radioactivity in the waste disposal systems and radioactive gases released

from the plant The bounding increases in effluent releases estimated by the licensee from the

proposed EPU are 171 percent for noble gases 176 percent for gaseous radionuclides with

short half-lives and 153 percent for tritium while a higher secondary side moisture carryover

could result in a bounding increase of 253 percent in iodine releases

The licensees evaluation concluded that the proposed EPU would not change the

radioactive gaseous waste systems design function and reliability to safely control and process

the waste The projected gaseous release following EPU would remain bounded by the values

given in the FES for PTN Units 3 and 4 The existing equipment and plant procedures that

control radioactive releases to the environment will continue to be used to maintain radioactive

gaseous releases within the dose limits of 10 CFR 201302 and the as low as is reasonably

achievable (ALARA) dose objectives in Appendix I to 10 CFR Part 50

Radioactive Liquid Effluents

The liquid waste management system collects processes and prepares radioactive

liquid waste for disposal Radioactive liquid wastes include liquids from various equipment

drains floor drains the chemical and volume control system steam generator blowdown

chemistry laboratory drains laundry drains decontamination area drains and liquids used to

transfer solid radioactive waste The licensees evaluation shows that the proposed EPU

implementation would not significantly increase the inventory of liquid normally processed by the

liquid waste management system This is because the system functions are not changing and

the volume inputs remain the same The proposed EPU would result in a 153-percent increase

31 shy

in the equilibrium radioactivity in the reactor coolant which in turn would impact the

concentrations of radioactive nuclides in the waste disposal systems

Since the composition of the radioactive material in the waste and the volume of

radioactive material processed through the system are not expected to significantly change the

current design and operation of the radioactive liquid waste system will accommodate the

effects of the proposed EPU The projected liquid effluent release following EPU would remain

bounded by the values given in the FES for PTN Units 3 and 4 The existing equipment and

plant procedures that control radioactive releases to the environment will continue to be used to

maintain radioactive liquid releases within the dose limits of 10 CFR 201302 and ALARA dose

standards in Appendix I to 10 CFR Part 50

Radioactive Solid Wastes

Radioactive solid wastes include solids recovered from the reactor coolant systems

solids that come into contact with the radioactive liquids or gases and solids used in the reactor

coolant system operation The licensee evaluated the potential effects of the proposed EPU on

the solid waste management system The largest volume of radioactive solid waste is low-level

radioactive waste (LLRW) which includes sludge oily waste bead resin spent filters and dry

active waste that result from routine plant operation refueling outages and routine

maintenance Dry active waste includes paper plastiC wood rubber glass floor sweepings

cloth metal and other types of waste generated during routine maintenance and outages

The licensee manages LLRW contractually and continues to ship Class A B and C

LLRW offsite for processing and disposal EnergySolutions Inc (with a Class A disposal facility

located in Clive utah) is currently under contract with FPL for the processing and disposal of

- 32

Class A LLRW Studsvik Inc is under contract with FPL for processing storage and disposal

of Class Band C LLRW

As stated by the licensee the proposed EPU would not have a significant effect on the

generation of radioactive solid waste volume from the primary reactor coolant and secondary

side systems since the systems functions are not changing and the volume inputs remain

consistent with historical generation rates The waste can be handled by the solid waste

management system without modification The equipment is designed and operated to process

the waste into a form that minimizes potential harm to the workers and the environment Waste

processing areas are monitored for radiation and there are safety features to ensure worker

doses are maintained within regulatory limits The proposed EPU would not generate a new

type of waste or create a new waste stream Therefore the impact from the proposed EPU on

the management of radioactive solid waste would not be significant

Occupational Radiation Dose at EPU Conditions

The licensee stated that the in-plant radiation sources are expected to increase

approximately linearly with the proposed increase in core power level To protect the workers

the licensees radiation protection program monitors radiation levels throughout the plant to

establish appropriate work controls training temporary shielding and protective equipment

requirements so that worker doses will remain within the dose limits of 10 CFR Part 20 and

ALARA

In addition to the work controls implemented by the radiation protection program

permanent and temporary shielding is used throughout PTN Units 3 and 4 to protect plant

personnel against radiation from the reactor and auxiliary systems containing radioactive

- 33shy

material The licensee determined that the current shielding design is adequate to offset the

increased radiation levels that are expected to occur from the proposed EPU since

bull conservative analytical techniques were used to establish the shielding requirements

bull conservatism in the original design basis reactor coolant source terms used to establish

the radiation zones and

bull Plant Technical Specification 348 which limits the reactor coolant concentrations to

levels significantly below the original design basis source terms

Based on the above the staff concludes that the proposed EPU is not expected to significantly

affect radiation levels within the plants and therefore there would not be a significant

radiological impact to the workers

Offsite Doses at EPU Conditions

The primary sources of offsite dose to members of the public from PTN Units 3 and 4

are radioactive gaseous and liquid effluents The contribution of radiation shine from plant

buildings and stored radioactive solid waste was evaluated by the licensee and found to be

negligible As previously discussed operation at the proposed EPU conditions will not change

the radioactive waste management systems abilities to perform their intended functions Also

there would be no change to the radiation monitoring system and procedures used to control the

release of radioactive effluents in accordance with NRC radiation protection standards in 10

CFR Part 20 and Appendix I to 10 CFR Part 50

Based on the above the offsite radiation dose to members of the public would continue

to be within NRC and EPA regulatory limits and therefore would not be significant

Spent Nuclear Fuel

- 34shy

Spent fuel from PTN Units 3 and 4 is stored in the plants spent fuel pool and in dry

casks in the Independent Spent Fuel Storage Installation The PTN Units 3 and 4 are licensed

to use uranium-dioxide fuel that has a maximum enrichment of 45 percent by weight uraniumshy

235 Approval of the proposed EPU would increase the maximum fuel enrichment to 5 percent

by weight uranium-235 The average fuel assembly discharge burnup for the proposed EPU is

expected to be approximately 52000 megawatt days per metric ton uranium (MWdMTU) with

no fuel pins exceeding the maximum fuel rod burnup limit of 62000 MWdMTU The licensees

fuel reload design goals will maintain the fuel cycles within the limits bounded by the impacts

analyzed in 10 CFR Part 51 Table S-3 - Table of Uranium Fuel Cycle Environmental Data and

Table S-4 - Environmental Impact of Transportation of Fuel and Waste to and from One Lightshy

Water-Cooled Nuclear Power Reactor as supplemented by NUREG-1437 Volume 1

Addendum1 Generic Environmental Impact Statement for License Renewal of Nuclear Plants

Main Report Section 63 - Transportation Table 91 Summary of findings on NEPA issues for

license renewal of nuclear power plants Therefore there would be no significant impacts

resulting from spent nuclear fuel

Postulated Design-Basis Accident Doses

Postulated design-basis accidents are evaluated by both the licensee and the NRC to

ensure that PTN Units 3 and 4 can withstand normal and abnormal transients and a broad

spectrum of postulated accidents without undue hazard to the health and safety of the public

On June 25 2009 the licensee submitted license amendment request (LAR) number

196 (LAR 196) Alternative Source Term to the NRC to update its design-basis accident

analysis In LAR 196 the licensee requested NRC approval to use a set of revised radiological

consequence analyses using the guidance in NRCs Regulatory Guide 1183 Alternative

- 35shy

Radiological Source Terms (AST) for Evaluating Design Basis Accidents at Nuclear Power

Reactors On June 25 2010 the licensee submitted a supplement to LAR 196 to revise the

radiological dose consequence analyses The analyses for LAR 196 are applicable for the

power level in the proposed EPU The NRC evaluated the proposed changes in LAR 196

separately from the EPU

In LAR 196 the licensee reviewed the various design-basis accident (DBA) analyses

performed in support of the proposed EPU for their potential radiological consequences and

concluded that the analyses adequately account for the effects of the proposed EPU The

licensee states that the results of the revised AST analysis were found to be acceptable with

respect to the radiological consequences of postulated DBAs since the calculated doses meet

the exposure guideline values specified in 10 CFR 5067 and General Design Criteria 19 in

Appendix A of 10 CFR Part 50

The results of the NRCs evaluation and conclusion approving the proposed changes

submitted in LAR 196 are documented in a Safety Evaluation related to Amendment Nos 244

and 240 for PTN Units 3 and 4 respectively (ADAMS Accession No ML110800666)

Radiological Cumulative Impacts

The radiological dose limits for protection of the public and workers have been

developed by the NRC and EPA to address the cumulative impact of acute and long-term

exposure to radiation and radioactive material These dose limits are specified in 10 CFR

Part 20 and 40 CFR Part 190

The cumulative radiation dose to the public and workers are required to be within the

regulations cited above The public dose limit of 25 millirem (025 millisieverts) in 40 CFR

Part 190 applies to all reactors that may be on a site and also includes any other nearby nuclear

- 36shy

power reactor facilities There is no other nuclear power reactor or uranium fuel cycle facility

located near PTN Units 3 and 4 The NRC staff reviewed several years of radiation dose data

contained in the licensees annual radioactive effluent release reports for PTN Units 3 and 4

The data demonstrate that the dose to members of the public from radioactive effluents is within

the limits of 10 CFR Part 20 and 40 CFR Part 190 To evaluate the projected dose at EPU

conditions for PTN Units 3 and 4 the NRC staff increased the actual dose data contained in the

reports by 15 percent The projected doses at EPU conditions remained within regulatory limits

Therefore the NRC staff concludes that there would not be a significant cumulative radiological

impact to members of the public from increased radioactive effluents from PTN Units 3 and 4 at

the proposed EPU operation

A COL application was submitted in June 2009 to the NRC to construct and operate two

new AP1000 reactor plants on the PTN site designated as Units 6 and 7 The FPL radiological

assessment of the radiation doses to members of the public from the proposed two new

reactors concluded that the doses would be within regulatory limits The staff expects continued

compliance with regulatory dose limits during PTN Units 3 and 4 operations at the proposed

EPU power level Therefore the staff concludes that the cumulative radiological impacts to

members of the public from increased radioactive effluents from the combined operations of

PTN Units 3 and 4 at EPU conditions and the proposed two new reactors would not be

significant

As previously discussed the licensee has a radiation protection program that maintains

worker doses within the dose limits in 10 CFR Part 20 during all phases of PTN Units 3 and 4

operations The NRC staff expects continued compliance with NRCs occupational dose limits

during operation at the proposed EPU power level Therefore the staff concludes that

- 37shy

operation of PTN Units 3 and 4 at the proposed EPU levels would not result in a significant

impact to the workers cumulative radiological dose

Radiological Impacts Summary

As discussed above the proposed EPU would not result in any significant radiological

impacts Table 2 summarizes the radiological environmental impacts of the proposed EPU at

PTN Units 3 and 4

Table 2 Summary of Radiological Environmental Impacts


Amount of additional radioactive gaseous effluents generated would be handled by the existing system


Amount of additional radioactive liquid effluents generated would be handled by the existing system

Occupational Radiation Doses

Occupational doses would continue to be maintained within NRC limits

Offsite Radiation Doses

Radiation doses to members of the public would remain below NRC and EPA radiation protection standards

Radioactive Solid Waste

Amount of additional radioactive solid waste generated would be handled by the existing system

I Spent Nuclear Fuel The spent fuel characteristics will remain within the bounding criteria used in the impact analysis in 10 CFR Part 51 Table S-3 and Table S-4


Calculated doses for postulated design-basis accidents would remain within NRC limits

Cumulative Radiological

Radiation doses to the public and plant workers would remain below NRC and EPA radiation protection standards

Alternatives to the Proposed Action

As an alternative to the proposed action the NRC staff considered denial of the

proposed EPU (ie the no-action alternative) Denial of the application would result in no

change in the current environmental impacts However if the EPU were not approved for PTN

- 38shy

Units 3 and 4 other agencies and electric power organizations may be required to pursue other

means such as fossil fuel or alternative fuel power generation to provide electric generation

capacity to offset future demand Construction and operation of such a fossil-fueled or

alternative-fueled plant could result in impacts in air quality land use and waste management

greater than those identified for the proposed EPU for PTN Units 3 and 4 Furthermore the

proposed EPU does not involve environmental impacts that are significantly different from those

originally identified in the PTN Unit 3 or Unit 4 FES and NUREG-1437 SEIS-5

Alternative Use of Resources

The action does not involve the use of any different resources than those previously

considered in the PTN Unit 3 or Unit 4 FES

Agencies and Persons Consulted

In accordance with its stated policy the NRC staff consulted with the FDEP SFWMD

Miami-Dade County BNP and FWCC regarding the environmental impact of the proposed

action and specifically regarding the monitoring and mitigation plan that formed the basis of the

Florida agencies recommending approval to the FDEP for the proposed EPU subject to the CoC

during the State of Florida site certification process

III Finding of No Significant Impact

On the basis of the details provided in the EA the NRC concludes that granting the

proposed EPU license amendment is not expected to cause impacts significantly greater than

current operations Therefore the proposed action of implementing the EPU for PTN Units 3

and 4 will not have a significant effect on the quality of the human environment because no

- 39shy

significant permanent changes are involved and the temporary impacts are within previously

disturbed areas at the site and the capacity of the plant systems Accordingly the NRC has

determined it is not necessary to prepare an environmental impact statement for the proposed

action

Dated at Rockville Maryland this 27th day of March 2012

I=AJ~~ LATORY COMMISSION

ason C Paige Project Manager Plant licensing Branch 2-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ENCLOSURE 2

Summary of Comments on the Draft Environmental Assessment and

Draft Finding of No Significant Impact

Background

The US Nuclear Regulatory Commission (NRC) staff published a notice in the Federal

Register requesting public review and comment on the draft Environmental Assessment (EA)

and draft Finding of No Significant Impact (FONSI) on November 17 2011 (76 FR 71379) and

established December 19 2011 as the deadline for submitting public comments By letters

dated December 9 2011 (Agencywide Documents Access and Management System (ADAMS)

Accession No ML11347A194) and December 122011 (ML 12027A023) comments were

received from Florida Power amp Light Company (FPL) and Mr Steve Torcise Jr of the Atlantic

Civil Inc respectively FPL comments provided new estimates on the number of additional

workers needed to support the outage work implementing the proposed Extended Power Uprate

(EPU) and revised the projected outage times necessary to implement the EPU FPL

comments have been incorporated into this final EA with no change to the FONSI conclusion

Atlantic Civil Inc comments have been incorporated into this final EA with no change to the

FONSI conclusion and are summarized below Also by letter dated January 12 2012

(ML 120 19A348) the Southeast Regional Office of the US Department of the InteriorS National

Park Service provided comments on the draft EA and draft FONS Since these comments

were received after the comment period deadline of December 19 2011 the NRC will address

these comments using separate correspondence

Disposition of Atlantic Civil Inc Comments

Summary of Comments

1 FPL claims that the cooling canal is a closed system but obviously it is not FPLs

monitoring data shows that the unlined cooling canal system exchanges water with adjacent

bullbullbull

- 2shy

ground water FDEP designated the groundwater within the cooling canal system as G-III

waters (non-potable aquifer not subject to compliance with groundwater standards) and the

NPDES Permit only authorized a discharge to those G-III waters FPLs groundwater

monitoring data shows that contaminants from the cooling canals have migrated west of Lshy

31 E and the interceptor ditch into G-II waters (See the attached figures)

2 In anticipation of directly causing saltwater intrusion the interceptor ditch was intended It

to restrict movement of saline water from the cooling water system westward of Levee 31E

adjacent to the cooling water system to those amounts which would occur without the

existence of the COOling canal system (SFWMD 1983) The interceptor ditch has not been

effective and has not contained the hypersaline water of the cooling canal system FPLs

monitoring data confirms this (See the attached figures 2 amp 3) These figures show the

chloride and tritium data collected by FPL in December 2010 and February 2011

respectively as an overlay on Figure 1 [Figures 1 2 amp 3 are provided in the December 12

2011 letter] This indicates water quality violations and warrants remedial action by FPL to

correct the problem before the uprate is initiated

3 FPL has not acknowledged controlled or adequately addressed the existing water quality

violation The proposed uprate will increase the salinity in the cooling canal system which

will exacerbate the existing water quality violation

4 Because of this unaddressed water quality violation other property owners have had to go

to extraordinary efforts and costs to prove that saltwater intrusion has not reached their

property The NPDES permit did not authorize any injury to the public or private property or

any invasion of personal rights nor authorize infringements of federal state or local laws or

regulations The rights of nearby property owners clearly have been violated by the cooling

systems influence on saltwater intrusion

- 3shy

5 Until FPL addresses the existing water quality violations the facility should not be allowed to

increase its output and there should not be a Finding of No Significant Impact for the

proposed uprate without mitigating the existing significant adverse impacts of the CCS This

Draft Environmental Assessment must mandate a solution to the impacts being cause by

the CSS today and the increased impacts that will result from the uprate

NRC Response

As discussed in the EA the closed-cycle cooling canal system (CCS) permitted by the

State of Florida as an industrial wastewater facility is used for the cooling of heated water

discharged from the main condensers and auxiliary systems of Turkey Point (PTN) Units 1

through 4 The CCS is operated under an industrial wastewater facility No Discharge National

Pollutant Discharge Elimination System (NPDES) permit issued by the State of Florida

Department of Environmental Protection (FDEP) for water discharges to an onsite closed-loop

recirculation cooling canal system In this case closed-loop recirculation means that the cooling

canal does not have a pipeline connection with water bodies surrounding the PTN site such as

Biscayne Bay for receiving or discharging its water Monitoring data show that there is indirect

surface water communication between the CCS and Biscayne Bay The NRC staff revised the

surface water and aquatic resources sections in the final EA to clarify that there is some water

exchange between the cooling canal and other water systems and that aquatic species within

the cooling canal are unable to travel into or out of the canal system

The FDEP completed a thorough and comprehensive review under the Florida Electrical

Power Plant Siting Act and issued a site certification to FPL approving the proposed EPU for

PTN Units 3 and 4 In accordance with the FDEP site certification process for the proposed

EPU FPL must meet state imposed requirements contained in the Conditions of Certification

(CoC) The CoC was developed based on interactions by FPL with the FDEP and other

stakeholders during the FDEP site certification process The inclusion of stakeholders

-4shy

recommendations into the CoC formed the basis for FDEP recommending approval of the site

certification application for the proposed EPU The CoC requires FPL to have a program to

monitor and assess the potential direct and indirect impacts to ground and surface water from

the proposed EPU The monitoring includes measuring water temperature and salinity in the

CCS and monitoring the American crocodile populations at the PTN site The monitoring plan

expands FPLs monitoring of the CCSs ground and surface water to include the land and water

bodies surrounding the PTN site such as Biscayne Bay The implementation of the CoC

monitoring plan is an ongoing program coordinated by FDEP The results of the monitoring will

be publicly available via a South Florida Water Management District (SFWMD) website If the

proposed EPU is approved by the NRC the CoC monitoring plan would continue to assess the

environmental impacts Among other measures the CoC allows FDEP to impose additional

measures if the monitoring data is insufficient to adequately evaluate environmental changes or

if the data indicates a significant degradation to aquatic resources by exceeding State or County

water quality standards or the monitoring plan is inconsistent with the goals and objectives of

the Comprehensive Everglades Restoration Plan Biscayne Bay Coastal Wetlands Project

Additional measures could include enhanced monitoring modeling or mitigation Abatement

actions provided in the CoC include mitigation measures to comply with State and local water

quality standards which may include methods to reduce and mitigate salinity levels in

groundwater operational changes to the PTN cooling canal system to reduce environmental

impacts and other measures required by FDEP in consultation with SFWMD and Miami-Dade

County to reduce the environmental impacts to acceptable levels

Non-radiological conditions in the PTN cooling canal system are the responsibility of the

State of Florida and its regional regulatory agencies The implementation of the CoC monitoring

plan is an ongoing program coordinated by FDEP FDEP is responsible for evaluating the

- 5 shy

monitoring data and has authority to impose mitigation measures as appropriate to ensure

aquatic resources are adequately protected

All radiological effluent discharges into the cooling canal are monitored and controlled in

accordance with NRC regulations NRC regulations require that radioactive gaseous and liquid

releases from nuclear power plants be monitored and must meet radiation dose-based limits

specified in 10 CFR Part 20 the as low as is reasonably achievable (ALARA) dose criteria in

Appendix I to 10 CFR Part 50 and the Environmental Protection Agencys radiation protection

standards in 40 CFR Part 190 These regulations limit the radiation dose that members of the

public might receive from radioactive material released by a nuclear power plant Nuclear

power plants are required to submit an annual report to the NRC on the types and amounts of

radioactive gaseous and liquid effluents released into the environment each year The annual

radioactive effluent release reports submitted to the NRC are available to the public through the

NRCs ADAMS electronic reading room on the NRC website (wwwnrcgov)

The NRC provides continuous oversight of each plant under the NRCs inspection and

enforcement programs The NRCs Reactor Oversight Process integrates the NRCs

inspection assessment and enforcement programs The operating reactor assessment

program evaluates the overall safety performance of operating commercial nuclear reactors and

communicates those results to licensee management members of the public and other

government agencies The assessment program collects information from inspections and

performance indicators in order to enable the NRC to arrive at objective conclusions about a

licensees safety performance Based on this assessment information the NRC determines the

appropriate level of agency response including supplemental inspection and pertinent

regulatory actions ranging from management meetings up to and including orders for plant

shutdown The NRC conducts follow-up actions as applicable to ensure that the corrective

actions designed to address performance weaknesses are effective

- 6shy

Clarifying and corrective changes were made to the EA based on the comments

received No changes were made to the EAs finding of no significant environmental impact

March 27 2012 Mr Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company PO Box 14000 Juno Beach Florida 33408-0420

SUBJECT TURKEY POINT UNITS 3 AND 4 - ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT RELATED TO THE PROPOSED EXTENDED POWER UPRA TE (TAC NOS ME4907 AND ME4908)

Dear Mr Nazar

Enclosed is a copy of the Environmental Assessment (EA) and Finding of No Significant Impact (FONSI) related to your request for an amendment dated October 21 2010 as supplemented on December 14 2010 and April 22 2011 (on environmental issues) for Turkey Point Units 3 and 4 The proposed amendment would authorize increasing the maximum thermal power from 2300 megawatts thermal (MWt) to 2644 MWt This represents a net increase in core thermal power of approximately 15 percent including a 13 percent power uprate and a 17 percent measurement uncertainty recapture over the current licensed thermal power level and is defined as an Extended Power Uprate (EPU)


Also enclosed is a summary of the comments received on the Draft EA and Draft FONSI that was published in the Federal Register on November 172011 (76 FR 71379)

Sincerely

IRA

Jason C Paige Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation





DISTRIBUTION PUBLIC LPL2-2 Branch Reading File RidsAcrsAcnw_MailCTR RidsNrrDlrRerb RidsNrrDorlLpl2-2 RidsNrrLABClayton RidsNrrPMTurkeyPoint RidsNrrPMNDifrancesco SKlementowicz NRR RidsOgcRp Resource RidsRgn2MailCenter Resource

ADAMS Accession Nos Package ML 12087 A360 Letter (NRR-1 06) ML1207 4A248 EA FRN (NRR-044) ML 12074A251 Summary of Comments ML12075A035

OFFICE LPL2-2PM LPL2-2LA RERBIBC OGC NLO LPL2-2BC

bull LSubin NAME JPaige BClayton Almboden (wI comments) DBroaddus

DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712

vla email OFFICIAL RECORD COpy

Letter to Mano Nazar from Jason Paige dated March 27 2012

Subject TURKEY POINT UNITS 3 AND 4middot ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT RELATED TO THE PROPOSED EXTENDED POWER UPRATE (TAC NOS ME4907 AND ME4908)

cc wencls

State of Florida Department of Environmental Protection

Cindy Mulkey Department of Environmental Protection Mail Station 48 3900 Commonwealth Blvd Tallahassee Florida 32399

Marc Harris Department of Environmental Protection Mail Station 48 3900 Commonwealth Blvd Tallahassee Florida 32399

South Florida Water Management District

Steve Krupa PG Hydrogeology Section SFWMD PO Box 24680 MS 4330 West Palm Beach FL 33416

Scott Burns Land Resources Staff SFWMD PO Box 24680 MS 4330 West Palm Beach FL 33416

MiamimiddotDade County Department of Environmental Resources Management

Craig K Grossenbacher Chief Natural Resources Planning Section Miami-Dade Department of Environmental Resources Management 701 NW 1 st Court 5th Floor Miami FL 33136-3912

National Park Service Biscayne National Park

Sarah Bellmund Biscayne National Park 9700 SW 328th Street Homestead FL 33033-5634

ENCLOSURE 1



License Amendment

















-2shy

















20852






I Introduction














(ML11115A114)









-4shy























- 5shy






















-6


in 2012




















- 7shy

























8shy








associated software















-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


ENCLOSURE 1



License Amendment

















-2shy

















20852






I Introduction














(ML11115A114)









-4shy























- 5shy






















-6


in 2012




















- 7shy

























8shy








associated software















-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712




License Amendment

















-2shy

















20852






I Introduction














(ML11115A114)









-4shy























- 5shy






















-6


in 2012




















- 7shy

























8shy








associated software















-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


-2shy

















20852






I Introduction














(ML11115A114)









-4shy























- 5shy






















-6


in 2012




















- 7shy

























8shy








associated software















-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


I Introduction














(ML11115A114)









-4shy























- 5shy






















-6


in 2012




















- 7shy

























8shy








associated software















-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


-4shy























- 5shy






















-6


in 2012




















- 7shy

























8shy








associated software















-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 5shy






















-6


in 2012




















- 7shy

























8shy








associated software















-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


-6


in 2012




















- 7shy

























8shy








associated software















-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 7shy

























8shy








associated software















-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


8shy








associated software















-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


-9shy








Air Quality Impacts















-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


-10shy

Water Use Impacts

Surface Water























- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 11 shy

























- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 12 shy

























- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 13shy








Groundwater















- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 14shy
























15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


15 shy








EPU
















- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 16shy
























- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 17 shy























- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 18shy


















Charadrius melodus


Mycteria americana



Vennivora bachmanii


piping plover T





Fish



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712



Amorpha crenulata


Chamaesyce garberi


Gaactia smalfii

Halophia johnson


Polygala smallii

- 19shy


deltoid spurge E

Garbers spurge T


Smalls milkpea E



tiny polygala E





Reptiles









Snails






- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 20shy























- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 21

























- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 22shy
















Palm Drive)









- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 23shy























- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 24shy
























- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 25shy























- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 26shy
























- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 27shy

























- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 28shy



















- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 29



















- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 30shy
























31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


31 shy























- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 32



















ALARA




- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 33shy






















Spent Nuclear Fuel

- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 34shy
























- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 35shy
























- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 36shy



















significant





- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 37shy






PTN Units 3 and 4





















- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 38shy






















- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 39shy




action




ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


ENCLOSURE 2



Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712




Background



















Summary of Comments



bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


bullbullbull

- 2shy

























- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 3shy






NRC Response




















-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


-4shy

























- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 5 shy


























- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


- 6shy





Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712




Dear Mr Nazar




Sincerely

IRA










DATE 031512 031512 030312 031912 032712

ILPL2-2PM

1 JPaige

032712


Turkey Point Nuclear Plant, Units 3 and 4 - Transmittal ... · Turkey Point (PTN), Units 3 and 4,...

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Transcript of Turkey Point Nuclear Plant, Units 3 and 4 - Transmittal ... · Turkey Point (PTN), Units 3 and 4,...